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CHS, Inc. v. Montana State Dept. of Revenue

CHS, Inc. v. Montana State Dept. of Revenue, 2013 MT 100 (April 16, 2013) (5-0) (McGrath, C.J.)

Issue: (1) Whether CHS’s challenge to DOR’s assessment methods may be brought as a declaratory judgment action in district court without first appealing to an administrative tax appeal board; (2) whether summary judgment was proper for CHS’s claim that DOR failed to equalize its valuation of CHS’s property; and (3) whether DOR’s assessment of CHS’s property was too late for 2009.

Short Answer: (1) No, as the only issues of fact CHS raised went to valuation; (2) yes; and (3) no.